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Important information for providers who subcontract services

July 5, 2017

During a recent audit, Independence identified an issue caused by a provider?s subcontractor separately billing Independence and/or our members for services that the subcontractor and its agent provided at the request of the provider.

As a reminder, all providers must notify Independence of any subcontractor agreements, in accordance with their Professional Provider Agreement and/or Hospital, Ancillary Facility, or Ancillary Provider Agreement (Agreement). If the subcontractor bills Independence and/or our members and Independence makes payments on any claims as a result of the providers? subcontracting agreements, the provider will be responsible for reimbursing Independence for payments from the subcontractor and/or the subcontractors? agents? billing.

An example of a subcontractor arrangement that caused Independence to recover payments from a provider is a hospital that subcontracted for Intraoperative Neuromuscular (INM) Testing services from a vendor (INM subcontractor). The INM subcontractor separately billed Independence and our members. Independence?s reimbursement includes payment for the operating room services rendered by the participating hospital?s INM subcontractor, as the services were required by the surgeon to complete the surgery. The services of all such similar technicians, such as a radiology technician or pulmonology technician are also included in the hospital?s reimbursement, including when the hospital subcontracts for such services. In this example, the hospital?s INM subcontractor?s claims included charges from an agent of the INM subcontractor, who is not on the hospital?s medical staff and is not a participating provider with Independence.

The hospital subcontractor billed and collected payments from Independence and our members. Hospitals are obligated under the terms of their Agreement to hold Independence and our members harmless from subcontractors, including the subcontractors? agents. Independence recovered these payments from the hospital that subcontracted for the services.

If you have any questions concerning a current audit, please send a detailed inquiry to ProviderAuditInquiries@ibx.com.


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